Introduction

We at Virtuoso Learning Limited (trading as “Kubicle”) know that you care about how your personal information is used and shared. We take your privacy seriously. We are also cognisant of our duties and responsibilities under European Union data protection law and the Data Protection Acts 1988 and 2003.

Please note that Virtuoso Learning Limited is the Data Controller of your personal data. The principles set out in this Privacy Notice apply to all instances in which Kubicle receives your personal data as a Data Controller for the purposes described in this notice. Those purposes are processing of data in order to participate in the various activities available on this website or as mentioned below.

We have structured this Privacy Notice so that it can be navigated easily, enabling you to find answers to your specific questions. However, feel free to read it in its entirety.

Please click on any of the topics below to be directed to the relevant information.

1. WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers our treatment of information from which an individual can be identified (“Personal Information”) that we gather when you are accessing or using our Website. This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

We do not knowingly collect or solicit Personal Information from anyone under the age of 16 or knowingly allow such persons to register for the Services (as that term is defined in our Kubicle Terms and Conditions which can be found at https://kubicle.com/terms). If you are under 16, please do not attempt to register for the Services or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 16 may provide any personal information to us or on the Services. In the event that we learn that we have collected personal information from a child under age 16 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 16, please contact us at support@kubicle.com.

2. WHAT INFORMATION DOES VIRTUOSOS LEARNING LIMITED COLLECT

We gather various types of Personal Information from our users, as explained more fully below. We may use this Personal Information to personalise and improve our services, to allow our users to set up a user account and profile, to contact users, to fulfill your requests for certain products and services, to analyze how users utilize the Website, and as otherwise set forth in this Privacy Policy. We may share certain types of Personal Information with third parties (as fully explained below). We collect the following types of information:

A. Information You Provide to Us:

We receive and store any information you knowingly provide to us. For example, we collect Personal Information such as your name, email address, physical address, browser information, location, and details of transactions you carry out through the Website. We will also record the way in which you use the Services and your performance metrics in respect of any assessments or tests that you take. If you contact us, we may keep a record of that correspondence. You can choose not to provide us with certain information, but then you may not be able to register with us or to take advantage of some of our features. We may anonymise your Personal Information so that you cannot be individually identified, and provide that information to our partners or other third parties.

B. Non-Personal Information Collected Automatically:

Whenever you interact with our Website, we automatically receive and record information on our server logs from your browser including your IP address, and the page you requested.

When we collect usage information (such as the numbers and frequency of visitors to the Website, the length of stay on the Website, the types of pages visited and other general information), we only use this data in aggregate form, and not in a manner that would identify you personally. For example, this aggregate data tells us how often users use parts of the Website, so that we can make the Website appealing to as many users as possible. We may also provide this aggregate information to our partners; our partners may use such information to understand how often and in what ways people use our Website, so that they, too, can provide you with an optimal experience. We never disclose aggregate information to a partner in a manner that would identify you personally.

C. E-mail and Other Communications:

We may contact you, by email or other means; for example, we may send you promotional offers on behalf of other businesses, or communicate with you about your use of the Website. Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of the Website, and you are responsible for reviewing such legal notices for changes.

3. HOW DOES VIRTUOSO LEARNING LIMITED USE COOKIES?

Whenever you interact with our Website, we automatically receive and record information on our server logs from your browser including information related to cookies. “Cookies” are identifiers we transfer to your computer or mobile device that allow us to recognize your browser or mobile device and tell us how and when pages in our Website are visited and by how many people. You may be able to change the preferences on your browser or mobile device to prevent or limit your computer or device’s acceptance of cookies, but this may prevent you from taking advantage of some of our Website’s features. Also, if you click on a link to a third party website, such third party may also transmit cookies to you. This Privacy Policy does not cover the use of cookies by any third parties.

4. WILL VIRTUOSO LEARNING LIMITED SHARE ANY OF THE PERSONAL INFORMATION IT RECEIVES?

We neither rent nor sell your Personal Information in personally identifiable form to anyone. We may share your Personal Information in personally identifiable form with third parties as described below.

A. Affiliated Businesses and Third Party Websites We Do Not Control: In certain situations, businesses or third party websites we’re affiliated with may sell items or provide services to you through the Website (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service.

B. Employers or other Third Parties:If you are using the Services at the request of some third party (for example, your employer or potential employer) and that party is paying for (or organising) your access to the Services, we may share your performance and usage metrics with that party. If you have signed up for the Services as a single user (and you are paying for the use of the Services yourself), we will not share your performance or usage metrics with any third party without your consent.

C. Agents: We employ other companies and people to perform tasks on our behalf and may need to share your information with them to provide products or services to you. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.

D. Business Tranfers: We may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that is transferred. Also, if we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information would be one of the assets transferred to or acquired by a third party.

E. Protection of Company and Others: We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with a legal obligation; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of Company, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

With Your Consent: Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information.

5. IS PERSONAL INFORMATION ABOUT ME SECURE?

Your account is protected by a password for your privacy and security. You must prevent unauthorised access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

We endeavour to protect the privacy of your account and other Personal Information we hold in our records, but we cannot guarantee complete security. Unauthorised entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. Transmission of information via the Internet can never be completely secure, and all such transmission is at your risk. The Website may contain links to other sites. We are not responsible for the privacy policies and/or practices on other sites. When following a link to another site you should read that site’s privacy policy.

6. WHERE CAN MY PERSONAL DATA BE TRANSFERRED?

Our servers are located in Ireland. In limited circumstances, Personal Information which we hold may be transferred to and visible in jurisdictions outside the European Economic Area (“EEA”). In particular, this may include the United States, Canada, South Africa and Australia. This will normally be the case where you are using the Services at the request of your employer or potential employer and that party is based outside the EEA (for example, in the US). As noted above, where your employer or potential employer is paying for your access to the Services, they will have access to your performance and usage metrics.

7. WHAT PERSONAL INFORMATION CAN I ACCESS?

Through your account settings, you may access, and, in some cases, edit or delete the following information you have provided to us:

1. name and password;
2. mail address;
3. location; and
4. user preferences.

You may inform us of any changes in your Personal Information, and in accordance with EU Data Protection Laws we will update or delete your Personal Information accordingly. To find out what Personal Information we hold on you or to have your Personal Information updated, amended or removed from our database, please email your request to us at DataPrivacyOfficer@Kubicle.com.

The information you can view, update, and delete may change as the Website changes. If you have any questions about viewing or updating information we have on file about you, please contact us at support@kubicle.com

You have the right to ask Virtuoso Learning Limited to provide you with all the information it stores on you. If you wish to access your personal data you can go to your account profile where you will have the opportunity to update your personal data or preferences. You have the right to request additional information about the handling of your personal data. You also have the right to object to the processing of your data by Virtuoso Learning Limited in some circumstances and, where we have asked for consent to process your data, to withdraw this consent. Additionally, you may contact our Data Protection Officer at dataprivacyofficer@kubicle.com if you would like assistance with any of the aforementioned rights.

There are exceptions to these rights, however. For example, access to personal data may be denied in some circumstances if making the information available would reveal personal information about another person or if Virtuoso Learning Limited is legally prevented from disclosing such information. In addition, Virtuoso Learning Limited may be able to retain data even if you withdraw your consent, where Virtuoso Learning Limited can demonstrate that it has a legal requirement to process your data

8. CAN I OPT-OUT OF SHARING MY PERSONAL DATA WITH VIRTUOSO LEARNING LIMITED?

Of course. You can always opt not to disclose information to use, but keep in mind some information may be needed to register with us or to take advantage of some of our features.

You may request full deletion of your account by contacting us at support@kubicle.com. Please note that some information may remain in our private records after your deletion of such information from your account but only to enable us to comply with our own legal obligations.

9. WHAT HAPPENS IF THIS PRIVACY POLICY CHANGES?

We may amend this Privacy Policy from time to time. In the event of any substantial changes, we will notify affected users of updates. We encourage you to review the policy from time to time.

10. WHO DO I CONTACT IF I HAVE ANY QUESTIONS OR CONCERNS?

The data controller responsible for your personal information for the purposes of the applicable European Union data protection law is:

Virtuoso Learning Limited
ATTN: Data Protection Officer
25 Crosbie House
Northbrook Avenue
Dublin 6
D06 YD61

Phone: +353 1 883 0702

Email: dataprivacyofficer@kubicle.com

Please note that Virtuoso Learning Limited, trading as the Kubicle, is an Irish company with the registration number 517835.

If you have any questions about this Privacy Notice or our data collection practices, please contact us at the address, telephone number or email listed above and specify your country of residence and the nature of your question.

Effective Date: March 7, 2018